Suffice it to say that anybody considering coming to the US for the purpose of getting a JAA night qualification that takes maybe 2 days at most - must be certifiable.
I am not arguing about whether various material should or should not be modified.
I am simply stating that training leading to a certification is considered 'more involved' and treated as a full course of study - as per that letter. The fact that Flight Training was specifically called out as such is itself indicative.